Importers of regulated energy-using products should treat the October 15, 2026 revision to D19-6-3 as a system-transition issue, not as a reason to immediately change their electronic filing settings. The memorandum reflects a transfer of regulatory responsibility and updates terminology, but it also directs importers to continue using the existing NRCan-related submission settings until the system changes are finalized. CBSA D19-6-3
What changed in D19-6-3
D19-6-3, Importation of Energy-using Products, was revised on October 15, 2026. The revision reflects the transfer of responsibility for the Energy Efficiency Regulations from Natural Resources Canada to Environment and Climate Change Canada. It also replaces the former “Single Window Initiative” terminology with “Customs Single Window.” CBSA D19-6-3
The practical point is that the agency name and program terminology have changed before all related system changes have been completed. The memorandum’s interim instruction is that importers should continue using the existing NRCan-related submission settings. The revised memorandum does not, based on the cited notice, announce an immediate requirement to replace those settings with new agency or program values. CBSA D19-6-3
Who should review the change
The revision is relevant to commercial importers of regulated energy-using products, including specified appliances and equipment. A business importing those products through Toronto or receiving them into distribution facilities in Mississauga or Brampton may have the change sitting inside its customs-entry, product-compliance and broker-instruction workflow rather than in its transportation process. CBSA D19-6-3
Importers whose products are not covered by the Energy Efficiency Regulations would not generally have a reason to change a customs process solely because D19-6-3 was revised. The first review question is therefore whether the goods fall within the regulated energy-using product category, rather than whether the importer is located in Ontario or uses a particular port or carrier.
Products and filing workflows
Importers who handle covered appliances or equipment should identify where energy-efficiency information enters their import process. Depending on the business’s workflow, that may include product master data, the customs broker’s entry instructions, integrated import-system data, release documentation or post-entry records.
The immediate control is continuity: existing NRCan-related submission settings should remain in use while the system transition is unfinished. Changing settings based only on the new agency name could create a mismatch between the importer’s instructions and the available system configuration. CBSA D19-6-3
What importers should discuss with their broker
A broker review should separate three questions that are easy to combine incorrectly:
- Product scope: Do the importer’s appliances or equipment fall within the energy-efficiency requirements addressed by D19-6-3?
- Submission configuration: Which existing NRCan-related settings are currently used for the importer’s entries, and should they remain unchanged during the transition?
- Change management: How will the broker and importer confirm when updated Customs Single Window settings are available and appropriate to use?
Importers may also want to give their broker a controlled list of affected stock-keeping units, tariff classifications and product descriptions. That list can help distinguish regulated products from unrelated goods and reduce the risk that a terminology change is applied across every import file.
Questions for internal teams
- Which products are currently treated as energy-using products for import purposes?
- Where are the current NRCan-related submission values stored: broker instructions, software templates, product data or shipment-level documents?
- Who is responsible for approving a future switch to updated Customs Single Window settings?
- How will the importer preserve a record of the settings used during the transition?
These are process-control questions rather than a direction to make an immediate system change. The cited memorandum’s interim instruction should be the reference point for the current filing approach. CBSA D19-6-3
How this differs from a customs accounting revision
D19-6-3 concerns the importation of energy-using products and the related regulatory submission workflow. It should not automatically be treated as a change to tariff classification, value for duty or the accounting treatment of every imported appliance.
That distinction matters because another September 2026 memorandum revision, D11-6-8, addressed verification of origin, tariff classification and value for duty in the CARM environment. D11-6-8 also reflects the replacement of the former B3-3 and B2 forms with the Commercial Accounting Declaration. CBSA D11-6-8
An importer of regulated equipment may therefore have two separate reviews: one for energy-efficiency information and submission settings under D19-6-3, and another for customs accounting records under D11-6-8. A change in one workflow should not be assumed to change the other.
Recommended file review before the next shipment
For affected importers, a targeted file review is more useful than a broad software reset. The review can include:
| Review area | Practical check |
|---|---|
| Product scope | Identify appliances and equipment that may be covered by the energy-efficiency requirements. |
| Broker instructions | Confirm that existing NRCan-related submission settings remain documented and active during the transition. |
| System data | Check product templates and integration fields for outdated labels without changing functional settings prematurely. |
| Accounting records | Keep energy-efficiency information separate from classification, origin and value-for-duty records. |
| Change approval | Assign responsibility for reviewing future Customs Single Window system updates. |
Importers with recurring shipments into GTA distribution operations should complete this review before sending revised instructions to a broker. For a Mississauga, Brampton or Toronto importer, the objective is to prevent a regulatory-name change from producing inconsistent shipment instructions across multiple facilities or suppliers.
Bottom line
The October 15 revision to D19-6-3 records an important responsibility and terminology change, but the immediate operational message is continuity. Importers of covered energy-using products should generally continue using the existing NRCan-related submission settings until the relevant system changes are finalized. They should also ask their broker to confirm which products, data fields and future change controls are affected. CBSA D19-6-3
This article is general information for Canadian trade participants and is not a determination that a particular product is regulated or that a specific filing is complete.